14 February 2008                                                                                     

Planning Services
Cannock Chase District Council.

Dear Sirs,

Bleak House Wind Farm

CPRE opposes the above proposal and advances the following arguments in support of our opposition.

PREAMBLE

In common with the government and other environmental organisations, global warming and the consequent need to promote energy saving, sustainable energy generation and conservation measure is high on our agenda. In practice CPRE sees the threat to our living standards by this and by other looming developments in the depletion of world basic resources such as water, minerals and importantly oil, in much more stark terms than many other bodies and public commentators.
We are however unconvinced that wind power in the form of on-shore wind turbine farms is defensible, although superficially and emotionally attractive. Power is available, at best, only 30% of the time, for most of its output it requires fossil fuel or nuclear generation back-up at enormous expense, and it is only economically viable when under-pinned by huge public subsidies. Even if demanding government targets were to be achieved it would only constitute a fraction of total energy needs, and by the time this programme is implemented just the rise in energy demand will have outstripped all its provision.
CPRE is a countryside protection body and the price to be paid for wind power on the scale envisaged is the domination of the cherished English landscape by wind turbines in vast and small arrays 300 feet high, visible from great distances by the need for their siting on exposed ground and made additionally intrusive by their light colouring and the uncoordinated and flickering motion of their sweeping turbine blades. Our judgement is that their size and domination is so insistent as to literally blot out the quieter, recessive country scene. There is no prospect of contemplative enjoyment of the landscape's natural beauty in their presence, nor any practical likelihood of finding any meaningful rural locations where they could be assimilated. Quite simply, the viewer's eye being commanded and held by the turbine towers' dominance and frantic movement, it becomes impossible to then comprehend the natural landscape free of this distraction whether close- up or distant.
In our view the only productive way forward in the energy debate is through energy conservation measures , reduction of consumption and production of environmentally-friendly clean power generation on a scale commensurate with our needs. The government's promotion of a new generation of nuclear power stations, when coupled with micro combined heat/power schemes on a district or domestic scale and radically-improved insulation standards point the correct direction. The visual blanketing of the English countryside, our proudest environmental asset by wind power generation installations should not be countenanced. Other benign solutions to the burgeoning energy and global warming crisis are available.

THE POLICY BACKGROUND
The site of the proposal is an area of exposed high ground at the southern edge of Cannock Chase District in Staffordshire. The land is open countryside and totally within the South Staffordshire Green Belt. It closely adjoins the Cannock Chase Area of Outstanding Natural Beauty (AONB), a designation equivalent in its measures for landscape protection to a National Park and protects Cannock Chase, an area of heather moorland and forest, and its surrounding attractive countryside.
There are a multiplicity of planning policies at all levels - national, regional, county and district - specifically directed towards protecting areas with this high amenity rating and relevant to the application site. Attention is directed towards these, and references given to the applicants' submission document.

Nationally

A major indication of Government objectives are those in PPS7 which include "raising the quality of life and the environment in rural areas", and providing for "sensitive" exploitation of renewable energy sources in accordance with the policies set out in PPS22 - Renewable Energy. Regardless of other issues CPRE finds the current application proposals, by their very nature, diametrically at variance with the term "sensitive".PPS22 - Renewable Energy
For the purpose of our response to this application CPRE is happy to concede that the extracts from PPS22 are indicative of the main points of that document, and for easy cross-reference we include them here:-
Paragraph 1 (i) "Renewable energy developments should be capable of being accommodated throughout England in locations where the technology is viable and the environmental, economic and social impacts can be addressed satisfactorily."
Paragraph 1 (iv) "The wider environmental and economic benefits of all proposals for renewable energy projects, whatever their scale, are material considerations that should be given significant weight in determining whether proposals should be granted planning permission".
Paragraph 1 (v) "Regional planning bodies and local planning bodies should not make assumptions about the technical and commercial viability of renewable energy projects".
Paragraph 1 (viii) "Development proposals should demonstrate any environmental, economic and social benefits as well as how any environmental social impacts have been minimised through careful consideration of local, scale, design and other measures."
These environmental effects are considered in chapters 6-14 of the Environmental Statement.
Paragraph 2-3 "The Regional Spatial Strategy should include the target for renewable energy capacity in the region….
As discussed earlier in this chapter the Regional Spatial Strategy states that the region has a renewable energy target of 10% by 2010.
Paragraph 13 "Policy on Green Belts is set out in PPG2. When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development which may impact on the openness of the Green Belt. Careful consideration will therefore need to be given to the visual impacts of the projects, and developers will need to demonstrate very special circumstances that clearly outweigh any harm by reason of inappropriateness and any other harm if projects are to proceed. Such very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources".
Paragraph 14 "Regional planning bodies and local planning authorities should not create "buffer zones" around international or nationally designed areas and apply policies to these zones that prevent the development of renewable energy projects."
Paragraph 15 "Local landscape and local nature conservation designations should not be used in themselves to refuse planning permission for renewable energy developments. Planning applications for renewable energy developments in such areas should be assessed in criteria based policies set out in local development documents, including any criteria that are specific to the type of area concerned."
As we say in the preamble to this objection, CPRE is in the forefront of the campaign to combat global warming but we feel that of the many strategies to be adopted for this purpose, land-based wind farms are the least viable, one of the most expensive and certainly the most destructive environmentally.

PPS22 is careful to use the phrase "renewable energy" throughout and avoid specific reference to wind farms. It is also notable that whilst urging renewable energy developments, in every case such development is conditional upon environmental concerns being satisfied.

Regionally
The RSS sets out criteria to be used when assessing environmental impact of energy generation proposals. These include, inter alia, "impact on the landscape visual amenity …." (5.3.1). Policy QE6 aims to "conserve, enhance and restore the quality of the Region's landscapes, seeks to establish a positive and integrated approach to the use, management and enhancement of the urban fringe" - which describes this location (5.3.2).

County-wide
The Staffordshire and Stoke on Trent Structure Plan (CSP) includes a specific policy on wind turbines. Policy PEP6 states:-
"Proposals for the generation of power from renewal energy source will be permitted provided that the proposed development would not cause demonstrable harm to interests of acknowledged importance".
The necessary criteria include:-
"show that the development would not result in an unacceptable intrusion on the intrinsic landscape quality of the area, [or] unacceptably affect the amenity of any neighbouring occupiers".
Specifically the policy refers to Cannock Chase AONB (500 metres from this site), saying that
"Proposals for the erection of wind turbines within Cannock Chase will not be permitted if they would have a significant adverse impact on the landscape quality"

CPRE argues that wind turbines of the height proposed, and in an extended array, cannot be defended as "lying outside the AONB boundary".
Policy NC2 of the CSP deals directly with landscape protection and restoration across the County, and its policy is forceful, lucid and comprehensively stated:-
"Development should be informed by and be sympathetic to landscape character and quality and should contribute to the regeneration, restoration, enhancement, maintenance or active conservation of the landscape likely to be affected. Proposals with landscape and visual implications will be assessed having regard to the extent to which they would:-
a) cause unacceptable visual harm
b) introduce ……… incongruous landscape elements
c) cause the disturbance or loss of:-
i) landscape elements that contribute to local distinctiveness
iv) the visual condition of landscape elements
v) tranquillity

Supplementary Planning Guidance (SPG) to amplify Policy NC2 was adopted entitled "Planning for Landscape Change" to which the Planning Authority's attention is drawn. It assesses compliance with Structure Plan Policy NC2 and amplifies considerations relevant to meeting landscape policy objectives.
The SPG included a map defining areas with different landscape policy objectives. This site falls within an area meriting the objective of "landscape restoration" (a reference to its restoration following earlier open cast coal mining), and this objective is later expanded.
Policy NC3 directly relates to the protection of Cannock Chase AONB with the primary object of conserving the natural beauty of its open and wooded landscapes. The policy states that:-
"The landscape quality of the Cannock Chase AONB and its setting (CPRE emphasis by underlining) will be conserved and enhanced, and its nature conservation and recreational value protected and extended. Proposals for development within the AONB will be subjected to special scrutiny having regard to the economic and social well-being of the area, and most particularly to the environmental effects of the proposal. Development will be restricted to uses compatible with the conservation of the area's natural beauty, and major industrial or commercial development will not be permitted unless proven national interest and lack of alternative sites can justify an exception. The acceptability of development proposals outside the AONB boundary will be assessed with regard to the extent of any adverse impact on the landscape, nature conservation or recreation interest of the AONB".
CPRE also draws attention to para 9.7 of the above policy referring to "the zones around the AONB".

Locally
The Cannock Chase District Local Plan deals specifically with the AONB and its purlieus in Policy C8:-
"The integrity of the Cannock Chase AONB will be protected in the following way:-
i) The District Council will strive to conserve and enhance the landscape, nature conservation and recreation interest of the AONB and its setting; (CPRE emphasis)
ii) Only development which is compatible with the conservation of the natural beauty of the AONB, and is in accordance with other relevant policies of the Local Plan, will be permitted;
iii) Proposals for development on the fringes of the AONB will be considered in the context of the primary objective of protecting the area's qualities.

The Green Belt
The purpose of the Green Belt, within which the application site is contained, is defined in Government Guidance PPG2 as to:-
i) check urban sprawl
ii) safeguard the surrounding countryside
iii) prevent neighbouring settlements from merging
iv) preserve the setting and special character of historic towns
v) assist urban regeneration
Purposes i, ii, and iii are obviously directly relevant to the application site, iv and v less so.
As far as development in the Green Belt is concerned, County Structure Plan Policy D5B states that
inappropriate development within Green Belts will not be permitted except in very special circumstances, (defined as)
a) infilling in villages (not relevant)
b) agriculture and forestry
c) essential facilities for outdoor sport and recreation, cemeteries and other uses compatible with the openness of the Green Belt (CPRE emphasis)
d) building extensions (not relevant)
e) infilling of developed sites (not relevant)"
"Re-use of buildings within the Green Belt may be appropriate provided the new use does not have a materially greater impact on the openness and quality of the Green Belt, and that any conversion work does not disproportionately increase the size of buildings and is in keeping with the surrounding".
"All development within the Green Belt should maintain the visual amenities of the Green Belt and will be subject to other relevant policies".
The Local Plan reiterates the Structure Plan and PPG2 policies in its own Policy C1. Policy C6, in developing policies for the AONB and Green Belt, states
"Should development be justified, buildings and associated landscaping will be designed as far as practicable to be in keeping with the local characteristics of the area".
The Cannock Chase Local Plan will ultimately be succeeded by the Local Development Framework. At its current stage it proposes policies which are relevant to this application:-
Policy 1B
- encourages wind farms subject to careful assessment of all …. environmental impacts
- whilst this policy encourages planting to assimilate new proposals such a remedy is not available for the wind farm
Policy 2A
- design principles that ensure an attractive and high quality environmental …. relate with …. surrounding environment …. and enhance the character and appearance of the area
- landscaping and screening to help avoid adverse effect of loss of amenity on adjacent properties ….
Both these environmental protection clauses would be flagrantly breached by the proposal.
Policy 2J
- is specifically devoted to wind turbines within or around the AONB which will not be permitted if they would have a significant effect on its landscape quality and require to be demonstrated no significant detrimental effect or any unacceptable intrusion on the landscape quality of the area
Policy 6A
- referring to the Green Belt - "presumes against use of land which would have a materially greater impact than the present use on the openness of the Green Belt".

LANDSCAPE AND VISUAL EFFECTS
The site, upon which it is proposed to erect these wind turbines 102 metres (337ft) high is on outlier hill of the adjacent Cannock Chase, dominant in both immediate and longer-range views. An indication of its prominence is seen from the 1" contour maps and from Figs. 6.6, 6.7, 6.8 and 6.9 of the applicants' Environmental Statement Vol 1. These show the theoretical range of visibility of firstly the blade tips' height within 10 kilometres, secondly the turbine hubs' height within the same distance, and thirdly and fourthly the visibility for both turbine elements at 30 km range.
The tower heights of 60 metres (200ft) are equivalent to a 22 storey block of flats (a 15 storey block features in Fig 6.29 for comparison), the total height of 102 metres (337 ft) to blade tips equivalent to a 37 storey building would be more than twice as high as that illustration. Whilst the turbine towers would be more slender than the flats illustrated, the slimness would accentuate height, the blades would be moving objects drawing attention, the uniform light colouring would be an insistent emphasis, and three such towers are proposed.

Taken together these illustrations and Figures give a forceful indication of the insistent presence of the turbines over the wider area.

Of equal, if not greater concern, is the domination of near and middle distance views. Topographically the site is partially ringed at a lower level by existing housing which benefits at present by the open views and wide skies, and by the sweep of skyline enjoyed and protected by its Green Belt designation. To this must be added the strong feeling of this location being a natural extension of Cannock Chase itself, whose Area of Outstanding Natural Beauty (AONB) designation falls only 500 metres (1650 ft) from the nearest turbine.
This close proximity of such tall and dominant engineering structures to an area classified nationally for its "natural beauty" would inevitably run counter to the purposes of such an area which they would diminish by their presence. If tourist attraction is conceded to be one of the economic purposes for such a place of wild beauty, then there is also an economic price to be paid for its downgrading.

THE POLICY BACKGROUND
In Part II of this objection we have thought fit to set out the principal planning policies which are seen to govern the approach to development on a site in this location. It is striking to a remarkable degree how strong, forceful and applicable to the current circumstances are these policies in seeking to protect, conserve and enhance here the natural environment and we have drawn attention to these by underlining the relevant sections.

Cannock Chase AONB - Although adjoining the application site, reference is made (NC3) to its setting being conserved and enhanced, and also to development proposals outside the AONB boundary being assessed with regard to the extent of any adverse impact .…… Similarly Cannock Chase District Council refers (C8) to protecting the AONB's integrity and its special values "and its setting".

In its wider context the West Midlands Region Spatial Strategy (WMRSS) aims to "conserve, enhance and restore the quality and diversity of the Region's landscape and to establish a positive and integrated approach to the use, management and enhancement of the urban fringe. The term "urban fringe" is transparently relevant to the application site, and therefore also the WMRSS policy.

Green Belt - The whole of the application site lies within the designated Green Belt at a point where its functions are especially appropriate and critical, notably in "checking urban sprawl, safeguarding the surrounding countryside" (especially relevant to the setting of the AONB), "preventing neighbouring settlements from merging". The visual impact of the proposed wind farm is such that the area's openness would be literally overwhelmed. Local Plan policies require the "maintenance of the visual amenities of the Green Belt" and for any justified development to be "designed as far as is practicable to be in keeping with the local characteristics of the area". CPRE asserts the impossibility of the proposed wind turbine towers complying in the slightest degree with these policies by any rational interpretation.

CPRE places great importance on recent assurances by the Prime Minister and by successive Ministers on the continued protection to be afforded to Green Belts in pursuing other Government policies.
CPRE strongly maintains that location and scale are already determined in the application, and there is little or not scope for design or detail modifications which would have insignificant and marginal effects compared to the environmentally devastating effect of "location and scale".
Para 13 "Policy on Green Belts is set out in PPG2. When located in the Green Belt, elements of many renewable energy projects will comprise inappropriate development which may impact on the openness of the Green Belt. Careful consideration will therefore need to be given to the visual impacts of the projects, and developers will need to demonstrate very special circumstances that clearly outweigh any harm by reason of inappropriateness and any other harm if projects are to proceed. Such very special circumstances may include the wider environmental benefits associated with increased production of energy from renewable sources".

CPRE believes the degree of harm to the Green Belt to be evident and substantial and incapable of being remedied or ameliorated in any meaningful way.
"Very special circumstances" obviously refers to the benefits claimed for wind power. If these are to be advanced in support of the proposal, objectors must be enfranchised to dispute the arguments as a matter of justice. This clause seems to be contrary to para 1 (i).
Para 14 "Planning bodies …. should not create "buffer zones" around …. nationally designed areas and apply policies to these zones that prevent the development of renewable energy projects."

CPRE notes that no such zones have been created around the AONB, but the effect upon the AONB from the erection of 102 metre high turbine towers near to their boundary is a material factor which could not be ignored in theory or practice
It should be noted in this respect that PPS23 contradicts the above PPS22 argument by advising that "…. any consideration of the …. potential impacts arising from development is capable of being a material planning consideration as far as it may arise from or may affect any land use.

CHAPTER 6 LANDSCAPE AND VISUAL EFFECTS
6.1.2 CPRE takes issue with 6.1.2 description of the site; "presence" of residential areas would more reflects the relationship. We are surprised that consultations did not apparently include Staffordshire County Council who were responsible for developing the Landscape Character definitions forming the basis for the Structure Plan policies.
6.2.8 As regards Wireline Visualisation and Photo-montages, CPRE makes the point that these do not accurately reflect the human perception of the view. In practice the vertical element is much more strongly perceived by human bi-polar eyesight, hence the greatly dramatised effect of the vertical dimension and its strong element of punctuation and attraction of the eye eg a church spire in a landscape view, or the towering effect of a mountain.
The same arguments apply to the prominence of distant objects. This prominence is greatly minimised by photographic representation as will be readily comprehended by any photographer. In this present context the illustrations fail to reflect actual visual impact experienced by the onlooker.
6.2.10 Impact magnitude fails to take into account the impact of an alien presence, either by experiencing a strange or discordant object, or an object appearing in an unaccustomed place. This is especially so on a landscape horizon whose horizontality is disrupted by objects both vertical and mechanical in form.
It is appropriate here to introduce the question of disturbance to the view by moving objects, ie the turbine blades. A landscape view is, of its very nature, unmoving, tranquil and restful; therein lies much of its charm and attractiveness - the eye can rest on the view. Fast, jerky, uncoordinated movement by the turbine blades is the very antithesis of the quiet rural scene which people value.

We are concerned that the visual evaluation process by the developers is an arithmetical and mechanical process failing to address the intangible elements of scenic beauty, tranquillity and presence of nature which are at the heart of people's concerns.

6.5 Assessment of Potential Effects
CPRE is initially concerned with the report summarising the "effects" from a limited number of viewpoints. The experiencing of the effects of the turbine towers will be a) a "serial" impact as one moves around the locality and see this discordant and dominating array from many directions, in unexpected glimpses and for lengthier periods of time, and b) the experience of residents for whom what was a comforting permanent undisturbed background hill-top rounded skyline becomes an industrialised scene of movement and distraction; an ever-present domination to their lives seen along the street, through their windows across their gardens and above their rooftops, c) for people resorting to the Cannock Chase Area of Outstanding Natural Beauty the downgrading of the experience and diminution of enjoyment. It must be repeated that these are giant structures on the very boundary of what has the status of a National Park and the shock of their impact would be correspondingly great.
Of further concern is the breach of trust and confidence in the democratic system of planning control which should be the concern of government at all levels. Every single environmental policy of the planning authorities at all levels would be broken by this proposal; the Green Belt, arguably the most popular and effective planning policy of long-standing is to be breached in the most flagrant way. Government seeks to strengthen public participation in the planning process; we would suggest that to contemplate such a proposal is to flout the very concept.
At this point we must press the inequitable nature of this application for local residents surrounding this site. For many years they have been subjected to the operation of open-cast coal working, but with the promise of landscape restoration to follow. To now contemplate the erection of wind turbine towers would compound the injustice.
Additionally, the impact of the line of towers will be reinforced by being seen by the majority of residents at an acute angle which visually will close up the group and increase the solidity of its effect.

The additional point we would wish to make in this section are the conclusions - "significance of effects" - after summarising each location attributes. In each case we contend that the "significance of effect" is down-played, after the "magnitude of effect" has more accurately assessed the impact. As a result the relatively anodyne verdict - "moderate adverse" frequently and unjustifiably appears.
This seems largely due to the perceived presence at the receptor site of a less attractive immediate environment, and the apparent unjustified verdict that those enjoying present high life quality will have their environmental experience downgraded to the greatest extent! It could be argued with equal or more force that the less advantaged gain greater value from an unsullied outward landscape view, and therefore are more damaged by the blight of wind farms. This attitude is translated into a similar approach in the wider landscape where in the View 20 location, the presence of Rugeley Power Station is considered to mitigate rather than accentuate the damage caused by the additional presence of the turbine farm!

In our view, although the descriptive material in this section is relatively objective, the conclusions drawn unduly minimise the visual damage of the turbines. To these judgements however must be added the basic negative factors of this proposal on the purposes of the Green Belt policy and under environmental consequences.
It cannot be stressed too strongly that it is the wind turbines' intrusiveness by virtue of their size, height and movement and their incongruity because of their nature as giant pieces of machinery in an overwhelmingly natural country scene that is the visual objection. The somewhat esoteric and continued attempts to analyse and explain away individual aspects of their presence is unhelpful in that context.

ADDITIONAL IMPACTS

Although there are several other aspects of the proposal to which it is possible to take exception, and CPRE will outline these if the application advances to further stages beyond its initial consideration, we would especially wish to draw attention to three particular matters. These are the sections in Chapter 8, Ornithology; Chapter 11, Noise; and Chapter 14.5 dealing with flicker.

Chapter 8, Ornithology
CPRE is concerned at the virtual dismissal of the effect on bird life and activity due to wind turbine operation.
The bank of 3 rotors stretches for over half a mile and its 102 metres high rotors sweep an area of 5500 sq metres or nearly 2½ acres, aligned across the prevailing wind. These rotors have a tip speed of between 164 and 90 miles per hour, the speed of a striking bird of prey, and with the rotors "attacking" from all angles. Traversing this hazard, birds will approach from all directions, not necessarily at right angles as assumed by the calculations offered, with a correspondingly increased period within the rotors' strike path. Birds taking panic avoiding action from the rotor strike, may well confusedly fly into the path of another blade. Wind turbulence from the rotor blades would inhibit the birds' manoeuvring reaction, compounded by the confusing factors of the blades' noise and their light flicker.
The figures quoted for calculated bird deaths at wind farms are at variance with the experience reported to us at operating sites where operating staff are allegedly employed to gather up bird victims of turbine strikes to avoid public outcry. If the applicants believe their own submission, they would presumably welcome a planning condition which requires independent verification of bird deaths, any increase over the quoted figures involving voluntary closure of the site.
If, indeed, the deterrence to birds restricts their flight patterns and reduces their range and freedom of flight, CPRE contends that this is a substantial detriment to wild life. One of the huge pleasures for human beings of enjoyment of open countryside is that of watching birds, their habits and flight patterns against the open sky and in peace. Quite simply, that pleasure will be denied by the noise, disturbance and distress caused by bird deaths, additional to other environmental losses set out elsewhere. This pleasure is intensely expressed in song and verse. "The lark ascending", its song uplifting the human spirit, will be the experience withdrawn as a consequence of the proposal. "What profits a man if he gains the whole world yet loses his soul" (St Mark 8:36) will be a sentiment that many would feel at this loss.

Chapter 11, Noise
It would have been helpful if noise levels quoted could have been related to commonly accepted criteria. We do not comment on construction noise effects, annoying though these may be, as in our view the operating conditions are those most severely detrimental as a continuing experience.
Table 11.6 figures indicate that with the exception of three sites, the projected raw noise levels are commensurate with quiet, outdoor normal background noise at 35dbA. Prospect Village, Chase Terrace and Burntwood locations would exceed this. CPRE would be concerned at the "nature" of the noise, a recurring, repetitive sudden "thump" which would potentially be more insistent and disturbing than a continuous low noise.
CPRE would be most concerned however on the effects on people using the footpaths across the site where the noise levels at 52dbA - 54dbA and higher would be considered loud in this rural situation, would effectively blot out all natural sounds including bird song, and eliminate the peace, quiet and tranquillity element of the countryside experience.

Chapter 14.5, Shadow Flicker
CPRE considers the effect of shadow flicker as being grossly under-stated in the Environmental Statement.
Its effect on properties has been partially mitigated by the prospect of ceasing operations when these conditions operate. It must be accepted however that under most conditions people using the site will be directly affected by the flicker of blades obscuring - or reflecting - sunlight. Of even more disturbing consequence is shadow movement across the ground, fast shadows at accelerating and decreasing speeds as they move towards, away or across the viewer's sightline. In traffic situations this can be dangerous and distracting for the vehicle driver who reacts to such movement in his peripheral vision. We request the planning authority to send observers to experience this unnerving phenomenon, equally upsetting to the pedestrian.

CONCLUSION
In this submission CPRE has dealt with only, in its view, the most important of the consequences of the proposal.
We note that this is an unusual application in that it effectively offends against not only the entirety of planning policies designed to protect the rural environment, including the Green Belt and an Area of Outstanding Natural Beauty, but also the setting and outlook of large numbers of people's homes around the site, an impact on the home environment.
It dominates a wide area for many miles by its height - as high as Castle Ring, equal to the highest ground on this side of Cannock Chase, and its elevation accentuates the upward angle as viewed by nearby residents and travellers.
Its contribution to sustainable energy is minuscule - one third of people's electrical energy which is itself one third of domestic energy use, which again is one third of total energy used, less than 4% of the whole and only for 9000 houses, less than one quarter of Cannock housing numbers. When the wind doesn't blow - or blows too hard - energy generation stops; another third of capacity lost which has to be made up by permanent base-load stations at massive capital costs.
CPRE has pointed out the many alternative ways in which energy can be conserved and sustainably supplied in response to the global warming and energy supply crises. The final clinching point is the fact that this proposal is only intended to last 25 years in which case it is unwarranted, but if it lasts for a longer period as is likely, environmental destruction becomes to all intents and purposes permanent.
CPRE's assessment is that benefits are slight and environmental damage overwhelming. The quality of life would be damaged, possibly beyond feasible remedy
The proposal should be refused.

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